GLOBAL PRIVACY POLICY (EN)

(Valid from: october 2025)


1. Introduction

This Privacy Policy explains how iNKPPL Tattoo Magazine (“we”, “us”, “the Site”, “iNKPPL”) collects, uses, stores, transfers and protects personal data of visitors and registered users (“you”, “Users”) of inkppl.com and inkppl.ru (collectively, “the Website”).

This Policy applies to all processing of personal data carried out by the Global Operator and its authorized partners worldwide.

By using the Website, you confirm that you have read and understood this Privacy Policy.

If you do not agree with its terms, please discontinue use of the Website.


2. Data Controller and Contact Information

2.1. Global Data Controller (Main Operator)

Individual Entrepreneur (Sole Proprietor)
Aleksandr Ledovskikh (Georgia)

Registered in Georgia
Address: Tbilisi, Chugureti District, Mikheil Tsinamdashvili St. 52
Email: info@inkppl.com

This entity is the primary controller of all personal data processed through inkppl.com.


2.2. Local Representative for Russia

For Users located in the Russian Federation, personal data may also be processed by:

Individual Entrepreneur
Aleksandr Andreevich Ledovskikh (Russia)

Acting as a local representative and processing partner in accordance with Russian Federal Law No. 152-FZ “On Personal Data”.

The Russian representative does not act as the main controller and processes data only as required by local legislation.


2.3. EU/UK/EEA Representative

We may appoint a separate representative for the EU/EEA or UK if required by GDPR/UK GDPR.
Up-to-date information will be available on this page.


3. Categories of Data We Process

We process the following categories of data:

3.1. Data you provide voluntarily

  • login / username

  • full name

  • email address

  • profile photo

  • links to social networks

  • portfolio photos

  • country and city

  • tattoo style, studio details

  • additional information you choose to include in your profile or submissions


3.2. Automatically collected data

Collected via cookies, pixels, logs, and analytics:

  • IP address

  • device and browser information

  • operating system

  • geographic region (approximate)

  • language

  • actions performed on the Website

  • access time, referral URLs

  • cookie identifiers and advertising identifiers


3.3. Data received through embedded content

When you interact with:

  • Instagram embeds

  • YouTube videos

  • Google Maps

  • Pinterest content

  • external analytics

those platforms may receive your data according to their own policies.


3.4. Data related to content submission

When submitting:

  • tattoo portfolio

  • articles or interviews

  • applications (artist, model, studio)
    we may collect:

  • biographical details

  • artistic information

  • links to your works

  • professional background


3.5. AI-generated and automated processing data

The Website may use automated systems for:

  • moderation of uploaded content

  • spam prevention

  • SEO analysis

  • image categorization by style

  • internal analytics using AI tools

These systems are designed not to make decisions with legal or significant personal impact.


4. Legal Grounds for Processing

Depending on your region, we process data on the following grounds:

For all Users (Georgia law)

  • your consent

  • performance of a contract (e.g., registration, account access)

  • legitimate interest (analytics, security, fraud prevention, content relevance)

  • compliance with legal obligations

For EU/EEA/UK Users (GDPR / UK GDPR)

  • Art. 6(1)(a) — consent

  • Art. 6(1)(b) — performance of contract

  • Art. 6(1)(f) — legitimate interests

  • Art. 6(1)(c) — legal obligations

For Russia

— in accordance with Russian Federal Law 152-FZ, see Russian Privacy Addendum.


5. Purposes of Data Processing

We use your data for:

  1. Creating and maintaining your user account

  2. Displaying your profile to other Users

  3. Website functionality and personalization

  4. Communication (email, notifications)

  5. Prevention of fraud, abuse, spam

  6. Analytics and performance monitoring

  7. Content moderation and quality improvement

  8. Processing submissions, interviews, portfolios, applications

  9. Advertising and marketing (where allowed by law)

  10. Compliance with legal requirements of applicable jurisdictions


6. Cookies and Tracking Technologies

We use:

  • essential cookies

  • analytics cookies (e.g., Google Analytics, Matomo, Yandex Metrica where allowed)

  • advertising pixels (e.g., Meta Pixel, Google Ads)

  • Cloudflare security cookies

  • session cookies

You can manage cookies in your browser settings.


7. Third-Party Processing and Data Transfers

We may share data with:

  • hosting providers

  • email delivery services

  • analytics platforms

  • content delivery networks (CDN)

  • AI moderation services

  • Cloudflare

  • services you voluntarily interact with (e.g., Instagram embeds)

We do not sell personal data.

7.1. International Transfers

Data may be transferred:

  • within the EU/EEA

  • outside the EU

  • to the United States

  • to Georgia

  • to other regions

Transfers are safeguarded using:

  • Standard Contractual Clauses (SCC)

  • adequacy decisions

  • contracts ensuring equivalent protection


8. Data Retention

We store data only as long as necessary for:

  • account operation

  • legal compliance

  • preventing fraud

  • maintaining archives for published interviews/materials

User accounts can be deleted upon request.

Portfolio photos and articles may remain in published materials, unless removal is legally required.


9. User Rights

For all Users

  • access to your data

  • correction

  • deletion

  • objection to processing

  • restriction of processing

  • data portability (where technically possible)

  • withdrawal of consent

For EU/UK Users

Rights under GDPR Arts. 12–23 apply fully.

For Users in Russia

Rights are provided under 152-FZ (detailed in Russian Addendum).

You may submit a request to: info@inkppl.com


10. Russian Privacy Addendum

Users located in the Russian Federation are additionally subject to the Russian Privacy Addendum, which supplements this Policy and ensures compliance with Federal Law 152-FZ.

The Georgian operator remains the primary controller.


11. Children’s Data

The Website is not directed to children under 16 (or as defined by local law).
We do not knowingly collect children’s data.


12. Security Measures

We implement:

  • HTTPS encryption

  • Cloudflare protection

  • intrusion detection

  • encrypted backups

  • access control

  • periodic security audits

No method of transmission is 100% secure, but we continuously improve protections.


13. Changes to This Policy

We may update this Privacy Policy.
Updates will be posted at:
https://inkppl.com/privacy

If changes are significant, we will notify Users through the Website or email.


14. Contact Information

Questions regarding this Policy:

info@inkppl.com

Users from Russia may also contact the local representative (ИП РФ) as described in the Addendum.